Dec. 13, 2023
Hi – By way of introduction, I serve as General Counsel for Monument Group, Inc., a FINRA- and SEC-registered broker-dealer specializing in the placement of private funds and secondary fund interests to institutional investors. I had submitted a comment on FINRA 23-09 (https://www.finra.org/sites/default/files/NoticeComment/Monument%20Group%20Inc_Molly%20Diggins_23-09_Projections%20Comment%20Letter_Execution%20Version_08.30.2023.pdf) and was pleased to see that FINRA had submitted the Notice of Filing for a proposed rule change to FINRA Rule 2210 to permit projections in institutional communications. I am, however, concerned that many of the proposed rule’s onerous compliance prerequisites for the use of projections by FINRA members will hold negative competitive and economic implications for independent placement agents. Unfortunately, however, due to both end-of-year work demands and the holiday “rush”, I will not be able to submit a comment prior to the December 15th deadline. I’m not sure if others in the industry have raised similar concerns with the deadline, but I respectfully ask the SEC to consider extending the deadline for such comments until the middle or end of January. Thanks very much for your consideration of my request. Best, Molly Diggins Molly Diggins | Partner, General Counsel Monument Group